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Packaging Act - how to implement it correctly

Katharina Rösner
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Do you want groceries or others products Putting into circulation is an important part of wrapping. This regulates the Packaging Act (VerpackG or EPR). In this article, you will find out what is in the law and what you need to consider.

What is the Packaging Act?

The Packaging Act regulates what you need to consider when you Products packaged or more Attaching packaging to a product. It applies to First time distributor of packaging. First time distributors are those who have a Be the first to put packaged goods into circulation, which private households finally dispose of. According to law, hotels or restaurants are also considered private households.

The Packaging Act wants to start when manufacturing and placing packaging on the market sustainability achieve. For the disposal of packaging, there is also a five-level hierarchy. The first stage is the Waste prevention. If this is not possible, as a manufacturer, you are required to send packaging to a circuit to supply. In addition, packaging should recyclable and friendly as well as from renewable raw materials be designed or consist of recycled material.

Since 1993, manufacturers have been paying for the disposal and recycling of packaging. In 2019, the Packaging Act resolved VerpackG the Packaging Ordinance. Since then, there have been a few innovations such as the Reusable rate. For example, 70 percent of beverage packaging should consist of reusable systems. The Packaging Act also states that customers must at least have the choice between disposable or reusable packaging. In addition restricted It the substances, the in packaging may be contained. In 2025, for example, PFAS should be restricted in packaging.

How is compliance with the Packaging Act checked?

The Packaging Act is regulated by Central Packaging Register Office (ZSVR) Checks what this is also for packaging register LUCID was created. There you have to Register as manufacturer. As a filler, you are also automatically a manufacturer — an exception is service packaging such as coffee mugs or bread bags, which you can buy pre-licensed. As a beverage manufacturer, you register, for example, the cardboard packaging of six-packs and the glass or plastic bottles as well as their caps.

The background to registration with the testing body is Responsibility as manufacturer for your packaging in terms of avoiding, recycling and reusing packaging. The aim is also transparency and to create fairness with regard to packaging disposal at home and abroad. The register is therefore also available to everyone. In 2024, there was one million registrations. The ZSVR recognizes administrative offenses and informs the country's authorities. To date, the audit body has reported 20,000 administrative offenses.

What packaging is available?

There is Packaging subject to system participation and not subject to system participation. Basically, you must register all packaging in the LUCID register. However, you do not have to license all packaging with a dual system.

Die Persons subject to system participation Packaging types are shipping package, repackaging, product packaging And the service packaging. For this, you buy from a dual system a packaging license — before you start your business or open your online shop.

Persons subject to non-system participation Packaging is transport packaging, Pre-licensed service packaging and Non-packaging.

Create a special case Disposable beverage packaging, which you must also register. For single-use beverage packaging, there is Pledge obligationWhich is why you have them at DPG, who German deposit system GmbH, Involved. The deposit is required for all plastic bottles with a capacity of between 0.1 and 3.0 liters. This also applies to juice, sparkling wine or wine. For Wine and sparkling wine in glass bottles However, there is no deposit system. However, the following are exempted from the deposit obligation beverage cartons — regardless of whether it is cylindrical, gable or block-shaped.

reusable beverage packaging You must register, but no packaging license buy from a dual system. However, you need a take-back and recycling concept for this.

What are dual systems?

The dual systems, such as The green point or EKO point take over the disposal and recycling of waste from consumers. That is why you also participate as a manufacturer by purchasing a packaging license there. Because of this System participation In a dual system, for example, the paper bin and the recycling bin are free of charge for private households. You also report the data that you report in the LUCID register in the dual system.

Which packaging do I need to license?

In principle, you must register all types of packaging with LUCID. Shipping and product packaging Do you also have to license with a dual system, as they have the consumers strain. In addition, there are Service packaging subject to participation. But since they come from Last operator are placed on the market, legislation allows the use of pre-licensed service packaging. This applies, for example, to bakeries with disposable cups and roll bags. Manufacturers are then responsible for licensing as the initial distributors of the bags and cups.

transport packaging and reusable packaging Do you have to Don't participate. This is because transport packaging protects the product during transport and does not end up in household waste by end users. They are more commonly used in B2B business. Alternatively, you need a take-back and recycling concept for reusable systems. Reusable packaging can also Non-packaging be when you sell them as a product — i.e. reusable coffee mugs or cases, which are then not subject to system participation.

What are my obligations as a first-time distributor?

An obligation under the Packaging Act is both System participation as well as the withdrawal and Utilization of packaging. You must also be a manufacturer register in the packaging registerto obtain the LUCID number. If you trade in other European countries, you often also need the EPR number. In EU law, the Extended Producer Responsibility, even though each Member State has its own system.

In the packaging register Do you report all packaging by type and quantity. The calculation is based on the total quantity of a material, such as glass, paper or aluminum, multiplied by the number of packages that you are likely to put into circulation.

Die Declaration of completeness Do you have to hand in if you circulate more than 30,000 kg of aluminum or plastic, 50,000 kg of cardboard, paper or cardboard, or more than 80,000 kg of glass per year.

What do I have to consider when it comes to my online shop?

If you have your own online shop Operate, must you depending on the product all accruing wraps register or license. This can be the product packaging and shipping packaging. You should yourself before the start of business register and ensure that you meet all requirements, because sentences of up to 200,000 euros or Sales bans can be imposed. Even as a regional direct marketer with an online shop, you must register packaging.

What do I have to consider when it comes to online marketplaces?

Do you use one online marketplace, You must also register the packaging and license it accordingly. Die platform is obliges, that to control. If you're not registered, it will stop selling your products. In dropshipping, retailers are responsible for the packaging if they are based in Germany.

Beverage packaging: reusable or disposable?

The advantage of disposable returnable bottles is that new high-quality bottles and textiles can be produced. However, material losses occur during the recycling process. As a result, only 75 new bottles can be created from 100 bottles. A closed circuit Is therefore not potential. Reusable bottles must be reused as often as possible to make transportation costs worthwhile.

Which packaging is the best for my products?

If you are looking for the right packaging for your products, you must not only food safety too environmental aspects pay attention. All unnecessary packaging that is often used by marketing serve, should you reconsider as a manufacturer. Consumers are also unfriendly Cheating packs, which are to be banned in 2025. The Packaging Act states that packaging recyclable, recyclable And off renewable raw materials should be designed. You should stick to this in order to save costs and not pollute consumers and the environment. You should always consider these when designing your packaging concept.

Recycling-friendly means Single-material packaging. Plastic packaging can be made of various plastics exist. In this case, they cannot be assigned to any of the 11 recycling paths and are therefore problematic. Because then all that remains is thermal recovery. Auch Composite packaging such as beverage cartons consist of at least two materials. Although there are now technologies to break down beverage cartons into their components, for example, they are rarely used.

This category also includes full sleeve packaging, the for bottles are popular. If they are not separable or made from different materials, they are only used thermally in the end. The same applies to barrier layers, which ensure that groceries Like cheese longer tenable are. Since packaging must also be safe, you can Don't always avoid.

Bad are also black packagingbecause scanners in sorting systems cannot distinguish them from the assembly line and they are automatically incinerated. This also applies bamboo, wood, cork, jute and ceramicbecause the Packaging Act does not set any quotas for them. For Organic packaging There is currently no recovery path and is only used thermally. Such “new” packaging is therefore not necessarily better than conventional packaging. When choosing, you must also note that the If possible, packaging should not be heavier than the product.

conclusion

Before you put products on the market, you must Register packaging. You should exactly vet, which Subject to system participation are and which aren't. If you only put a small amount of packaging into circulation, the participation will be cheaper. However, for various reasons, such as Customer friendliness and sustainability As little packaging waste as possible is generated. As a manufacturer or filler, you should consider this right from the start. Since food packaging must also be safe, it is often unavoidable.

Even with a small business, small business or with your direct marketing, you are affected by the Packaging Act when you package your products. For your regional direct marketing Do we have from Freight pilot The appropriate ERP software for yourself

A highlight of FrachtPilot in the context of packaging: FrachtPilot can automatically Order entry Calculate deposit or (rental) fees for the respective packaging and add them to the order. Unique in the ERP-Software world!

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